Ingram Industries, Inc. & Subsidiaries - Page 2




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          section 6621(c).1  After agreements of the parties, the question            
          we consider is whether the cost of the work performed on                    
          petitioners’ towboat engines constituted a currently deductible             
          expense or whether it is to be capitalized.                                 
                                  FINDINGS OF FACT2                                   
          A.  Background                                                              
               During the taxable years 1992, 1993, and 1994, petitioners             
          were members of an affiliated group of corporations of which                
          Ingram Industries, Inc. (Ingram) was the common parent.  Ingram             
          maintained its principal offices in Nashville, Tennessee, on the            
          date the petition was filed in this case.  During the years in              
          issue, petitioners were a closely held, diversified group of                
          corporations engaged principally in the wholesale marketing and             
          distribution of microcomputer software and hardware; books and              
          prerecorded video cassettes; inland barge transportation                    
          services; energy-related manufacturing, production, and                     
          marketing; and insurance.  The barge transportation service was             
          conducted by three wholly owned subsidiaries of Ingram--Ingram              
          Barge Co., Inc., Ingram Towing Co., Inc., and Great River Marine            
          Service, Inc.                                                               


               1 All section references are to the Internal Revenue Code in           
          effect for the years under consideration, and all rule references           
          are to the Tax Court Rules of Practice and Procedure, unless                
          otherwise indicated.                                                        
               2 The parties’ stipulation of facts and the exhibits are               
          incorporated by this reference.                                             




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